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ZilLearn Work Terms and Policies

ZilLearn’s Service (as defined below) is provided by ZilLearn Pte. Ltd., incorporated in Singapore. The Terms of Use, Copyright, Trademark and Intellectual Property Policy, Privacy Policy and Cookie Policy govern your access and use of the Service (collectively, “ZilLearn Work Terms and Policies”). For more information, please see

https://about.zillearn.com.

By accessing and using ZilLearn’s Service, you acknowledge and agree to comply with and be bound by these Terms and Policies, unless your organization has entered into a separate written agreement with us, in which case those terms and conditions will take precedence over these Terms and Policies. The terms “ZilLearn”, “we“, “us“, and “our” refer to ZilLearn Pte. Ltd. The term “You” or “your” refers to the individual who is accessing and using ZilLearn’s Service pursuant to these Terms and Policies.

Please read these Terms and Policies carefully before accessing and using the Service.

The key definitions that apply on the Service are described below:

  • Students: Individuals authorized by their organization to access and use Courses (as defined below) and to provide Content (as defined below) anywhere on the Service;
  • Instructors: Individuals authorized by their organization to provide Courses and Content anywhere on the Service;
  • Administrators: Individuals authorized by their organization to administer the access and use of the Service by their Students and Instructors;
  • Visitors: Individuals accessing and using the Service in the course of browsing, not under the authorization of any organization but of their own accord;
  • Users: Individuals accessing and using the Service, as well as providing Content anywhere on the Service, who may include Students, Instructors, Administrators and Visitors on the Service;
  • Courses: Learning content and training materials, comprising lesson plans or outlines, attachments, hyperlinks, activities, quizzes, questions, descriptions and announcements that are created, uploaded, embedded, inserted, published, posted, submitted or otherwise made available by Instructors for access and use by Students on the Service;
  • Content: Courses, data and any other information, including without limitation, attachments, hyperlinks, answers, responses, discussions, descriptions, announcements, ratings, reviews and feedback that are created, uploaded, embedded, inserted, published, posted, submitted or otherwise made available by ZilLearn, our affiliates, partners, agents and Users anywhere on the Service;
  • ZilLearn Work: A workplace learning platform in web and mobile app formats, that facilitates self-directed learning within a diverse and distributed workforce and is designed to provide configurable and cost effective solutions to enable organizational learning and development; and
  • Service: ZilLearn Work and any other services and functionalities that enable Users to conduct various activities on ZilLearn Work.

Terms of Use

1. Modifications of Terms and Policies

ZilLearn reserves the right at any time, in our sole and absolute discretion, to modify our Terms and Policies by posting the changes on our Service. Changes become effective immediately after posting on our Service. For any material changes to these Terms and Policies, we will take reasonable steps to notify you in advance of such changes. In all cases, your continued access and use of the Service after publication of such changes, with or without notification, constitutes binding acceptance by you of these modified Terms and Policies. Notwithstanding the foregoing, no revision to these Terms and Policies will apply to any disputes between you and ZilLearn that arose prior to the date of such revision.

Please contact us if you have any questions about our Terms and Policies. If you wish to contact us, please raise a ticket here.

2.User Accounts

2.1. Capacity and Authority

Access and use of the Service are restricted to individuals at least eighteen (18) years of age, or those who possess legal parental or guardian consent, and are fully able and competent to enter into and be bound by these Terms and Policies. By accessing and using the Service, you represent and warrant that (i) if you are an individual accessing the Service on your own behalf, you are at least eighteen (18) years of age, or in possession of consent by a legal parent or guardian and have the authority to enter into and be bound by these Terms and Policies; and (ii) as you are accessing and using the Service on behalf of an organization (such as in the course of your employment), you have authority to act on behalf of such organization to bind the organization to these Terms and Policies.

2.2. User Account Terms

In order to access and use the Service, your Administrator will have to create a personal account (a unique number) for you with your name, a valid mobile phone number or a valid email address and an initial password (“User Account”). Upon logging in to your User Account for the first time, you will be prompted to change your password. You may use your mobile phone number, email address or any other methods allowed by your organization, such as scanning a QR code, as a means of logging in to your User Account.

You acknowledge and agree that you are solely responsible for maintaining the confidentiality of your User Account, including your password, and for all activities associated with or occurring under your User Account, where applicable. You must notify us immediately on learning of any unauthorized use of your User Account or any other breach of security. We may request some information from you to confirm that you are the owner of your User Account. Subject to these Terms and Policies and to the extent permissible under applicable laws, we cannot and will not be responsible for any loss or damage arising from your failure to comply with the foregoing requirements or as a result of use of your User Account, either with or without your knowledge, prior to you notifying us of unauthorized access to your User Account.

You further acknowledge and agree that you will not divulge or share access or information in respect of your User Account with any third party for any reason. Your User Account is non-transferable and no one else but you may access and use your User Account. In the event that you allow a third party, including a natural person who is a minor, to access and use your User Account (“Unauthorized User“), you represent and warrant that you will be fully responsible and liable for all actions of such Unauthorized User, including the consequences of all actions on the part of the Unauthorized User who breach these Terms and Policies.

You represent and warrant that all information provided by you is accurate, current and complete and that you will maintain and update your information to keep it accurate, current and complete, failing which, we reserve the right at any time, in our sole and absolute discretion, to terminate, suspend or restrict your access and use of the Service.

2.3. Deletion of User Account

You may request to delete your User Account by contacting your Administrator.

If you need help or encounter difficulty deleting your User Account, please contact us by raising a ticket here.

3.Communications from ZilLearn 

By accessing and using the Service, you acknowledge and agree that ZilLearn may communicate with you electronically, by posting a notice on the Service or sending an email to you, regarding security, privacy or administrative issues in respect of your access and use of the Service or these Terms and Policies.

4.Relationships on the Service

As a User on the Service, you acknowledge and agree that no direct licensing relationship is established between you and our affiliates, partners or agents when you access and use the Service. Any such direct licenses will be deemed null and void and a violation of these Terms and Policies.

Instead, it is ZilLearn (and where applicable, the relevant affiliate, partner or agent, via a sublicense granted to ZilLearn) that is providing you with a limited term, revocable, non-exclusive, non-transferable, non-sublicensable license to access and use the Service. Likewise, it is ZilLearn (via a sublicense granted by you) that is providing our affiliates, partners and agents with a limited term, revocable, non-exclusive, non-transferable, non-sublicensable license to access and use your Content in order to provide you with access and use of the Service.

ZilLearn reserves the right to modify or revoke any license granted to you to access and use the Service without prior notice in the event that we determine, in our sole and absolute discretion, that your access and use of the Service is in violation of these Terms and Policies.

5.Content and Behaviour Rules

You acknowledge and agree to access and use the Service in accordance with these Terms and Policies.

In addition to restrictions in the Terms and Policies, you will not provide any of the following Content (“Prohibited Content”) anywhere on the Service:

  • Content that appears to be in an  unfinished or nonsensical state, whether published intentionally or unintentionally;
  • Content that is obscene, indecent, sexually explicit, discriminatory or deceptive (such as impersonating another individual or entity);
  • Content that discusses unlawful activities with the intent to commit or encourage other Users to commit such activities;
  • Content that is likely to cause offence, embarrassment or annoyance to other Users;
  • Content that defames, harasses, threatens harms other Users;
  • Content that violates applicable local, state, national or international laws; or
  • Content that includes advertising, promotional materials or any other form of solicitation (commercial or otherwise).

You will not also engage in any of the following behaviour (“Prohibited Behaviour”) anywhere on the Service:

  • Access or use or attempt to access or use any other User Account that does not belong to you, or misrepresent or mask or attempt to misrepresent or mask your identity to anyone while accessing or using the Service;
  • Transmit any unsolicited advertisement, promotional material or any other form of solicitation (commercial or otherwise) through the Service or to other Users;
  • Access or use the Service for organized partisan political activities;
  • Engage in activities that require ZilLearn to pay any fees to third parties in relation to your activities;
  • Engage in activities that indicate or suggest to any third party, whether explicitly or implicitly, directly or indirectly, that the Service is your property;
  • Engage in activities that abuse ZilLearn’s resources, including our support services;
  • Engage in activities that are likely to cause offence, embarrassment or annoyance to other Users;
  • Engage in activities that defame, harass, threaten or harm other Users;
  • Engage in activities that violate applicable local, state, national or international laws;
  • Use any high-volume, automated or electronic means to access or use the Service (including without limitation, robots, spiders, scripts or web-scraping tools);
  • Frame the Service, place pop-up windows over the pages or otherwise affect the display of the pages; or
  • Interfere with or disrupt the Service, servers or networks connected to the Service, or disobey any requirements, procedures, policies or regulations of networks connected to the Service.
 

ZilLearn reserves the right at any time, in our sole and absolute discretion, to remove any Prohibited Content, or to terminate, suspend or restrict your access and use of the Service, if you provide Prohibited Content or engage in Prohibited Behaviour on the Platform or anywhere on the Service.

6.License to ZilLearn

To the extent that you provide Content on the Service, you represent and warrant to ZilLearn (and our affiliates, partners and agents) the following:

  • You have all the necessary rights, licenses and clearances to provide such Content and permit ZilLearn (and our affiliates, partners and agents, via a sublicense granted by ZilLearn) to access and use such Content in order to provide you with access and use of the Service, and that you irrevocably waive any rights of privacy, publicity, copyright, trademark and intellectual property rights or other rights of a similar nature, to the extent permissible under applicable laws, in respect of such access and use;
  • You will be responsible for the payment of any third party fees in respect of your provision of such Content;
  • Such Content is accurate and reasonably complete;
  • Such Content does not infringe or misappropriate any third party rights (including without limitation, privacy, publicity, copyright, trademark and intellectual property rights);
  • Such Content does not constitute fraudulent statements, misrepresentations or unfair business practices; and
  • Such Content does not contain information that you do not have the right to disclose under contractual confidentiality obligations or fiduciary duties.

 

7. Disclaimers

The Service is provided on an “as is” and “as available” basis using reasonable care and skill. You acknowledge and agree that your access and use of the Service is entirely at your own discretion and risk. ZilLearn (and our affiliates, partners and agents) make no representation or warranty about the suitability, reliability, availability, timeliness, security, completeness or accuracy of the Service, and expressly disclaim any warranties (express or implied), including implied warranties of merchantability, fitness for a particular purpose, as well as non-infringement of any copyright, trademark or intellectual property rights. ZilLearn (and our affiliates, partners and agents) make no representation or warranty that you will obtain specific results from your access and use of the Service. Some jurisdictions do not allow the exclusion of implied warranties, so some of the above exclusions may not apply to you.

Use of any information downloaded or generated from the Service, as well as accessing hyperlinks included in the Service to third party websites, data or resources maintained or controlled by entities other than ZilLearn (and our affiliates, partners and agents) will be at your own discretion and risk. You acknowledge and agree that ZilLearn (and our affiliates, partners and agents) will not be responsible whatsoever for any harm suffered by you in any way due to any third party websites, data or resources, even where they are accessed from, or referred or linked to such websites, data and resources by the Service. You further acknowledge and agree that ZilLearn (and our affiliates, partners and agents) will not be responsible for the availability of such third party websites, data and resources, do not endorse any advertisement, product, service or material on or available from such websites, data or resources and are not liable for any loss or damage which may be incurred by you as a result of the availability of those websites, data or resources, or as a result of any reliance placed by you on the suitability, reliability, timeliness, security, completeness, accuracy, merchantability, fitness for a particular purpose, as well as non-infringement of any copyright, trademark or intellectual property rights of those websites, data or resources, or any advertisement, product, service or material on or available from such websites, data or resources.

You will connect to the Service using any supported internet browser and be solely responsible for obtaining access to the internet and the equipment necessary to access and use the Service, as well as any associated fees and costs. You acknowledge and agree that you will be solely responsible for any damage to your computer system, mobile telephone, wireless device or data, or any liability associated with your access and use of the Service or any such information downloaded or generated from the Service. In particular, you acknowledge and agree that no advice or information, whether written or oral, obtained by you from the Service, will create any representation or warranty by ZilLearn (or our affiliates, partners or agents) not expressly stated in these Terms and Policies.

ZilLearn reserves the right in our sole and absolute discretion, to cease making available certain features of the Service, make any changes to the Service or discontinue their availability, without prior notice or the need to provide you with any reasons whatsoever, and that we will not have any liability to you whatsoever for any such action. You acknowledge and agree that under no circumstances will ZilLearn (or any of our affiliates, partners or agents) be held liable for such interruptions or lack of availability of the Service.

We will also not be responsible for delay or failure of our performance in the Service caused by events beyond our reasonable control (including without limitation, wars, hostilities or sabotages, natural disasters, electrical, internet or telecommunication outages and government restrictions)

8.Limitation of Liability

You acknowledge and agree that ZilLearn (and our affiliates, partners and agents) will not be liable to you for any consequential, indirect, punitive, special or incidental damages, whether foreseeable or unforeseeable, or for any losses or damages arising from claims for defamation, errors, loss of data or interruption of data or personal data breach, loss of revenue, loss of business, whether based on contract, tort, statutory or other law, and whether or not even if ZilLearn (and our affiliates, partners and agents) have been advised or should have been aware of the possibility of such losses or damages, arising out of or relating to (i) any of these Terms and Policies; (ii) your access and use of or inability to access and use the Service; (iii) your reliance on information generated from the Service; (iii) any transaction between you and any advertiser whose advertisement may appear on the Service; (vi) any changes which ZilLearn may make to the Service, or for any permanent or temporary cessation in the provision of the Service (or any features within the Service); or (viii) the deletion of, corruption, or failure to store any information maintained or transmitted through your access and use of the Service. Some jurisdictions do not allow the limitation or exclusion of liability, so some of the limitations may not apply to you.
Nothing in these Terms and Policies will exclude or limit liability for death or personal injury caused by the negligence of ZilLearn (and our affiliates, partners and agents).

9. Indemnity

You acknowledge and agree to indemnify, defend and hold harmless ZilLearn (and our officers, directors, agents, employees and assignees), our affiliates, partners and agents (and their respective officers, directors, agents, employees and assignees) from any and all claims, liabilities, expenses, losses and damages, including reasonable legal costs, made by any third party relating to or arising out of (i) your access and use of the Service in violation of these Terms and Policies; (ii) your access and use of the Service in violation of any law; or (iii) your Content in violation of any copyright, trademark or intellectual property right infringement.

10.Governing Law and Jurisdiction

ZilLearn’s Service is managed by ZilLearn Pte. Ltd., incorporated in Singapore. Both ZilLearn and you acknowledge and agree that any disputes arising out of or relating to these Terms and Policies, whether based on contract, tort, statutory or other law, will be governed by the laws of the Republic of Singapore and that both ZilLearn and you acknowledge and agree to submit to the exclusive jurisdiction of the courts for the Republic of Singapore.

Privacy Policy

ZilLearn is committed to protect the privacy of our Users and recognizes the importance of the personal information you have entrusted to us and believe that it is our responsibility to properly protect, manage, process and disclose your personal information. Our Privacy Policy can be found here.

In accessing and using the Service, you acknowledge and agree to abide by our Privacy Policy.

Changes to Terms and Policies

These Terms and Policies were published on June 21, 2022.

ZilLearn Work Privacy Policy

By accessing and using ZilLearn’s Service, you acknowledge and agree to abide by the Terms of Use, Copyright, Trademark and Intellectual Property Policy, Cookie Policy and this Privacy Policy (collectively, “ZilLearn Work Terms and Policies”). Unless otherwise specified, capitalized terms used in this Privacy Policy will have the same meaning as they do in the other Terms and Policies.

Please read this Privacy Policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us or a supervisory authority in the event you have a complaint.

Who we are

Our Service is operated by ZilLearn Pte. Ltd., incorporated in Singapore. For more information, please see https://about.zillearn.com.

We collect, use and are responsible for certain personal information about you when we provide our Service to you. When we do so we are regulated under the relevant laws and we are responsible for the protection of that personal information for purposes of those laws.

If you are a Singapore data subject, we are obligated to comply with the Personal Data Protection Act 2012 (Act No. 26 of 2012) (“PDPA”) in relation to the collection, use and disclosure of personal information for purposes of those laws.

If you are an European Union (“EU”) data subject, we are also regulated under the General Data Protection Regulation (“GDPR”) which applies across the EU and we are responsible as ‘controller’ of that personal information for purposes of those laws.

Throughout our Service we may link to third party websites owned and operated by our trusted third party service providers to make additional products and services available to you. These third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these third party websites, please consult their privacy policies as appropriate.

Why we collect your personal information

We collect personal information about you directly from you when you access and use our Service or indirectly, such as your browsing activities while on our Service (refer to ‘How we use cookies’ below).

The personal information we collect about you depends on the particular activities carried out on our Service. These personal information may include:

  • your name, email address, mobile number, password, as well as additional information such as your job title and company when your User Account is created;
  • details of any feedback you give us by phone, email, posting on the Service, raising a support ticket or via our social media handles; or
  • information about the Service we provide to you. 

We use these personal information to:

  • manage your User Account with us in respect of your access and use of the Service;
  • facilitate delivery and improvement of the Service you have subscribed to receive from us or our trusted third parties;
  • provide you with essential functionalities, or support and troubleshooting assistance on the Service;
  • enable you to access and use Courses as a Student, or set up and update your profile as an Instructor on the Service;
  • facilitate any marketing communications to you based on your preferences;
  • comply with our legal obligations (including regulatory requirements and law enforcement requests) in respect of your access and use of the Service;
  • prevent violations of applicable laws, resolve disputes, detect fraud and abuse, and maintain security in respect of your access and use of the Service;
  • protect against harm to the rights, property or safety of anyone in respect of your access and use of the Service; or
  • enforce our Terms and Policies in respect of your access and use of the Service.

Where we need to use your personal information collected for other purposes not specified in this Privacy Policy or use your personal information collected for specific purposes for other purposes, we will seek your consent in advance.

How do we handle personal information about minors

Our Service is not intended for use by anyone below the age of eighteen (18) and we do not knowingly collect or use personal information relating to minors.

Our legal basis for processing your personal information

We are required to have a legal basis for using your personal information, subject to the jurisdiction which you are a data subject in. There are various different legal bases on which we may rely, depending on what personal information we process and why.

The legal bases we may rely on include:

  • Consent: Where you have given us clear consent for us to process your personal information for a specific purpose.
  • Contract: Where our use of your personal information is necessary for a contract we have with your organization or because your organization has asked us to take specific steps before entering into a contract.
  • Legal obligation: Where our use of your personal information is necessary for us to comply with applicable laws (not including contractual obligations).
  • Public task: Where our use of your personal information is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
  • Legitimate interests: Where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests).
 

What personal information we collect, when and how we use them

For further details on when we collect for personal information, what we collect and how we use them, please see below:

When personal information is collectedWhat personal information we collectHow we use your information collected
When your User Account is created.

Account Management

We ask for:

  • your name, email address, mobile number, password, as well as additional information such as your job title and company.

Account Management

We ask for this:

  • to communicate with you regarding security, privacy or administrative issues in respect of your access and use of the Service; or
  • to notify you of any changes to the Service or our Terms and Policies which may affect your continued access and use of the Service.

When you access and use the Service, subject to your choices, including your privacy settings and the functionalities you access and use on the Service.

.

Delivery and Improvement of Service

We ask for information you provide to the Service, information generated by your access and use of the Service, as well as information queried and collected by the Service, including but not limited to:

  • your device IP address;
  • your independent device identifier;
  • your device manufacturer and equipment model;
  • your device operating system version;
  • Your device language settings;
  • your device network status (mobile signal and WiFi signal);
  • your device CPU and battery usage; and
  • your device read_logs.

Delivery and Improvement of Service

We ask for this to provide you with the Service you have subscribed to receive from us or our trusted third party service providers, and to improve our Service to you, including but not limited to:

  • verifying if you are able to access the Service normally and if you are doing so from the same device;
  • analyzing the cause and adapting the functional interface in the event of an abnormal usage based on your device model and operating system;
  • adapting the language settings based on your device language settings;
  • optimizing the network download speed based on your device network status;
  • identifying and solving the cause in the event of a program crash based on your usage logs;
  • overall server hosting, monitoring, maintenance, backup, storage, security and virtual infrastructure management ;
  • any other technical and non technical support in respect of your access and use of the Service; and
  • improving our Service by performing data trend analysis and market research in respect of your access and use of the Service.
When you access and use essential functionalities on the Service.

Device Settings

We ask for:

  • your permission to access your device camera, photo album or storage;
  • your permission to access your list of currently running programs and device memory usage; and
  • your device model information, device identifier, network address, operator information and network status information, and (for Android devices only) your MAC address, IMSI, IMEI and Android_ID.

Device Settings

We ask for this:

  • to enable you to scan QR codes or capture images, obtain image files or documents for uploading;
  • to ascertain if the app is the active window on your device and, depending on the status, adjust the playback format to optimize your app usage experience; and
  • to provide you with web browsing services.
When you contact us for assistance on the Service.

Support and Troubleshooting

We ask for:

  • your communication and call records, as well as any relevant content, such as your User Account information, contact information and other information you provide to prove relevant facts.

Support and Troubleshooting 

We ask for this:

  • to contact you, help you troubleshoot issues, and record issue solutions and outcomes.
When you access and use Courses  as a Student on the Service.

Blended Course Enrollment and Sign-in

We ask for:

  • your permission to access your device camera to scan the Course QR code and at the same time, retrieve your User Account information; and
  • your permission to access your device camera to scan the Course QR code.

Assignment and Examination Submissions 

We ask for:

  • your permission to access your device camera to capture images, your device photo album to obtain image files for uploading or your device storage to obtain documents for uploading; and
  • your permission to access your device camera to capture images or your device photo album to obtain image files for uploading.

Learning Achievement Management

We ask for:

  • your User Account information access to obtain your learning records.

Forum 

We ask for:

  • your permission to access your device camera to capture images or your device photo album to obtain image files for uploading.

Blended Course Enrollment and Sign-in

We ask for this:

  • to verify if you meet the enrollment requirements of the blended Course;
  • to complete your sign-in and record your attendance.

Assignment and Examination Submissions 

We ask for this:

  • to enable you to complete your assignment by uploading attachments, including files in image, Word, Excel and other formats; and
  • to enable you to complete examinations by uploading your answers in image format as needed in situations where answers may be complex.

Learning Achievement Management

We ask for this:

  • to provide you with the learning achievement functionality to record your learning data, award you with medals and certificates, as well as accumulate your learning points.

Forum 

We ask for this:

  • to enable you to add image files to posts or replies in the Forum.
When you set up and update your profile as an Instructor on the Service.

Instructor Information Management

We ask for:

  • your permission to access your device camera to capture images or your device photo album to obtain image files for uploading; and
  • information such as your work experience, teaching experience, qualifications and certifications.

Instructor Information Management

We ask for this:

  • to enable you to set up and update your Instructor profile picture; and
  • to enable you to set up and update your Instructor profile biography.
When you engage in various activities on the Service.

Marketing

We ask for:

  • your name, email address and data collected in respect of your activities on the Service.

Marketing

We ask for this:

to communicate with you about the products and services offered by us or our trusted third party service providers on our Service or third party products and services offered outside of our Service that we think you may be interested in, where we conduct tailored advertising to you by email, on our Service or via our social media handles (such as Facebook, Instagram, LinkedIn, Youtube or Twitter).

 

How long we store your personal information for

We rely on consent as the lawful basis for collecting and using your personal information, unless we are permitted by applicable laws to process your personal information without your consent.

We will keep your personal information until:

  • you terminate your User Account with us; or
  • we terminate your User Account with us.

Upon closure of your User Account, your personal information will generally stop being searchable by other Users on our Service within twenty-four (24) hours.

We will retain your personal information even after you have closed your User Account to comply with our legal obligations (including regulatory requirements and law enforcement requests), or if reasonably necessary to (i) prevent violations of applicable laws, resolve disputes, detect fraud and abuse, or maintain security; (ii) protect against harm to the rights, property or safety of anyone; or (iii) enforce our Terms and Policies, or to fulfill your request to ‘Unsubscribe’ from further marketing communications from us.

Information you have shared with other Users (for instance, via direct messaging and public wall posts) will remain visible after your User Account has been closed, and we have no control over information that other Users may have copied out of our Service.

Who we share your personal information with

We may share your personal information with third parties as described below:

  • With our trusted third party service providers in respect of your access and use of the Service, to facilitate delivery and improvement of the Service you have subscribed to receive and any marketing communications to you based on your preferences, and we require any service provider with whom we share your personal information to protect the confidentiality of such information and use it solely for the purposes for which it was shared;
  • With law enforcement or any other authorities in respect of your access and use of the Service, if required by applicable laws or requested as part of a judicial, governmental or legal inquiry, order or proceeding; or
  • As may be reasonably necessary in respect of your access and use of the Service, to:
  • prevent violations of applicable laws, resolve disputes, detect fraud and abuse, and maintain security; 
  • protect against harm to the rights, property or safety of anyone, who may include ZilLearn, our affiliates, partners, agents, other Users, third parties and the general public; or
  • enforce our Terms and Policies.

Some of these third parties may be based outside Singapore — for further information, including on how we safeguard your personal information when this occurs, please see ‘Transfer of your personal information out of Singapore’.

Transfer of your personal information out of Singapore

We may transfer your personal information to jurisdictions outside Singapore that we may notify you from time to time, for purposes set out in this Privacy Policy and subject to our personal information security obligations, such as jurisdictions in order for:

  • our trusted third party service providers to (i) facilitate the delivery and improvement of any the Service you have subscribed to receive; or (iii) facilitate any marketing communications based on your preferences; and
  • us to comply with our legal obligations (including regulatory requirements and law enforcement requests), or if reasonably necessary to (i) prevent violations of applicable laws, resolve disputes, detect fraud and abuse, or maintain security; (ii) protect against harm to the rights, property or safety of anyone; or (iii) enforce our Terms and Policies.
 

Some of these jurisdictions do not have the same data protection laws as Singapore (or if you are an EU data subject, do not have the same data protection laws as the European Economic Area (“EEA”)). Any transfer of your personal information will be subject to suitable relevant safeguards that are designed to protect your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. In respect of such transfers, we will ensure that any personal information transferred outside Singapore will be protected at a standard that is comparable to that under the Personal Data Protection Act 2012 (PDPA) and this Privacy Policy. We will not otherwise transfer your personal information outside of Singapore.

How we use cookies

A cookie is a small text file which is placed onto your device (such as a computer, smartphone or other electronic device) when you access and use our Service. We use cookies on our Service to help us recognize you and your device, and store information about your preferences and past actions. We also use other tracking technologies such as web beacons (sometimes called ‘tracking pixels’ or ‘clear gifs’) for similar purposes. A web beacon is a tiny graphic file that contains a unique identifier to notify us when you click on a link in our promotional email that directs you to our Service and to monitor how you use our Service

For further information on how we use cookies, our use of cookies, third party cookies and how to disable cookies, please see our Cookie Policy here.

Your rights

If you are a Singapore data subject, under the PDPA, you have a number of important rights. You have similar rights as a EU data subject under the GDPR. In summary, those include rights to:

  • fair processing of information and transparency over how we use your use personal information;
  • access to your personal information and to certain other supplementary information that this Privacy Policy is already designed to address;
  • require us to correct any mistakes in your personal information which we hold;
  • require the erasure of personal information concerning you in certain situations, where we will, upon your written request:
  1. return to you or delete all such personal information in our possession, including any copies of any part thereof;
  2. after returning or deleting all such personal information, provide you with written confirmation that we no longer possess any such personal information, except where we have to retain your personal information to comply with our legal obligations (including regulatory requirements and law enforcement requests), or if reasonably necessary to (i) prevent violations of applicable laws, resolve disputes, detect fraud and abuse, or maintain security; (ii) protect against harm to the rights, property or safety of anyone; or (iii) enforce our Terms and Policies; and
  3. where applicable, we will also instruct all third parties to whom we have disclosed such personal information to return or delete such personal information;
  • receive your personal information which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those personal information to selected third parties in certain situations;
  • object at any time to processing of personal information concerning you for direct marketing;
  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
  • object in certain other situations to our continued processing of your personal information; or
  • otherwise restrict our processing of your personal information in certain circumstances.

If you would like to exercise any of those rights, please:

  • contact us via your Administrator or contact us directly by raising a ticket here;
  • let us have enough information to identify you;
  • let us have proof of your identity and address (a copy of your driving license or passport, and a recent utility or credit card bill);
  • let us know the information to which your request relates; and
  • in relation to withdrawing your consent to being contacted for marketing purposes, in addition to contacting us, you may also:
  1. use the ‘Unsubscribe’ link in emails; or
  2. use the ‘Unsubscribe’ link in emails; or
 

Alternatively, you may exercise some of those rights on your own by:

  • accessing your personal information in your User Account via the “Me” tab of the app to (i) edit your profile; (ii) change your password; or (iii) correct any errors in your personal information; or
  • changing your device permission settings listed below to withdraw your consent:
Device system Where to change the permission settings
CameraMe → Permission settings → Camera
Photo albumMe → Permission settings → Photo album

After you have withdrawn your consent by exercising any of your above rights, we will no longer process the personal information corresponding to your withdrawn consent. Consequently, we may not be able to continue providing you with certain functionalities of the Service. In any event, your decision to withdraw your consent will not affect your personal information previously processed based on your consent.

Keeping your personal information secure

We have appropriate administrative, physical and technical security measures in place to prevent personal information from unauthorized or accidental access, collection, use, disclosure, copying, modification, disposal, corruption, loss, damage or destruction, which are calibrated according to the sensitivity of the data involved. We limit access to your personal information to those who have a genuine business need to know it. Those processing your personal information must do so only in an authorized manner and are subject to a duty of confidentiality.

Unfortunately, no system can be completely secured and we cannot guarantee that communications between you and ZilLearn on the Service or any personal information provided to us in connection with the data we collect about you on the Service, will be completely free from unauthorized access by third parties.

We also have procedures in place to deal with any suspected data security breaches. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

You are responsible for maintaining the security of your User Account, including your password. You must not, at any time, disclose your password to any third party. We will not be responsible and you acknowledge and agree that you will not hold us responsible for any loss or damage incurred by you whatsoever caused by your non-compliance to any of the foregoing.

How to complain

We hope that we can resolve any query or concern you raise about our use of your personal information.

If you have any complaint or grievance about how we are handling your personal information or about how we are complying with applicable laws relating to the protection of your personal information, we welcome you to contact us by raising a ticket here.

If you are a Singapore data subject, under the PDPA, you may lodge a complaint with the data protection authority, the Personal Data Protection Commission (“PDPC”).

If you are an EU data subject, the GDPR also gives you the right to lodge a complaint with a supervisory authority, in particular in the EU (or EEA) state where you work, normally live or where any alleged infringement of data protection laws has occurred.

How to contact us

Please contact us if you have any questions about our Privacy Policy.
If you wish to contact us, please raise a ticket here.

Changes to this Privacy Policy

This Privacy Policy was published on June 21, 2022.